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Today in Tax: How to Reduce Transfer Pricing Risks and Tax Penalties in Transactions with Overseas Affiliates
May 24, 2022
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Intercompany transfer pricing is an IRS enforcement priority, and can result in significant tax liabilities and higher penalties than in many other situations. Federal tax laws provide avenues to reduce or eliminate the enhanced transfer pricing pena...
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Today in Tax: Foreign Tax Credits Against Digital Service Taxes, Partial Spin-Off Structures, and Filing Relief for Equity Grants, Stock Sale Structuring, and Opportunity Zones
Brief commentary on recent cases, rulings, notices, and related federal tax guidance as of December 14, 2021. U.S. Agreements Expand Potential Tax Credits for Digital Service Taxes The global tax landscape is rapidly changing as countries around th...
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Today in Tax: Spin-off Structures in Mergers & Acquisitions
Nov 16, 2021
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Brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Corporations Permitted to Rely on Public Shareholder Data to Confirm Qualification for Tax-Free Spin-off and Subsequent Merger Tax free spin-off transact...
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Today in Tax: Qualified Small Business Stock, Opportunity Zones, Information Reporting for Digital Assets
A brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Medical Software Deemed a Qualifying Trade for Qualified Small Business Stock Gain Exclusion When certain criteria are met, stockholders may be able to...
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When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce in the United States (Part 2)
Introduction Part 1 of this series discussed the proposals adopted by various countries to impose taxes on the digital economy, particularly by taxing various types of digital advertising and other digital services. These taxes allow countries to re...
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IRS Issues (and Seeks Comments on) Standards for Qualifying an LLC as a 501(c)(3) Entity
Nov 08, 2021
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Traditionally, an entity applying for tax exempt status under Code Section 501(c)(3) will be a corporation. With the rise in popularity of the LLC over the last 25 years, it’s a wonder that LLCs are not used more frequently to apply for federal tax e...
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